Users will need to disclose to us certain Personal Data to enable us to provide them with the Services. This Privacy Policy (the “Privacy Policy”), expressly incorporated into our Terms and Conditions, explains how we collect, use and share your Personal Data and what steps we take to ensure it remains secured. Please ensure that you read the Privacy Policy carefully.
In this Privacy Policy the terms “we”, “us” and “our” refer to the Company and any of its affiliates, service providers or agents. The terms “you” and “your” refer to you, the individual accessing the Services, whether you are using the Services exclusively on your own behalf or on behalf of an Institution. Capitalised terms that are not expressly defined herein shall have the same meanings as those ascribed to them in the Terms and Conditions.
We reserve the right to amend, modify or supplement the Privacy Policy at any time without prior notice. We shall notify Users of any changes made to the Privacy Policy via a notification on the Website and/or via email. Any such changes will be effective from the date of uploading to the Website or from such effective date as expressly mentioned therein. Your continued access or use of the Services confirms your consent and agreement to any such changes made. Please ensure you keep abreast of future updates.
By accessing or using the Services you represent, warrant and undertake that you:
- are at least 18 years of age;
- have full legal capacity to consent and be bound by all of the terms, policies, practices and procedures set out herein;
- have read the Privacy Policy in full and consent and agree to it in its entirety; and
- will keep abreast of future updates to the Privacy Policy and where you do not agree or consent to any changes made, will stop accessing or using the Services immediately.
Where you disclose Personal Data on behalf of any other individual you represent, you warrant and undertake all of the above on behalf of that individual.
If you have any queries or concerns regarding the Privacy Policy, please contact us at [email protected].
1. Personal Data
“Data Protection Laws” means the Singapore Personal Data Protection Act 2012 (Act 26 of 2012) and the European Union’s General Data Protection Regulation (EU) 2016/679 (“GDPR”), as amended from time to time, together with any implementing acts or instruments, and any similar legislation that is applicable to you. The Data Protection Laws that will apply to you will largely be dependent on the jurisdiction in which you are located or resident.
“Personal Data” means any data relating to an identified individual or any data, whether true or false, about an individual who can be identified from that data on its own or from that data and other information to which we have or are reasonably likely to have access.
Personal Data which we may collect from you includes but is not limited to the following:
- Name, date of birth, gender, place of birth, citizenship, home address, telephone number, fax number, email address, signature;
- Passport information, national identity card information, driver’s license information, tax identification number, photograph, visa information, signature;
- Proofs of address or residence such as bank statements, utility bills, phone bills, tax returns;
- Payment related information such as bank account details, credit card information, credit history, Digital Payment Token addresses, source of funds information;
- Trading data such as account balances, trading activity, deposits, withdrawals and orders; and
- Information relating to your accessing the Website and Services such as username, password, account settings, preferences, membership details, cookies, IP addresses, domain names, browser details, server logs and device information.
2. Collection of Personal Data
We collect your Personal Data at various times including when you:
- Register for an Account or to use any of the Services;
- Contact us with a query or request for assistance;
- Interact with us in through any medium e.g. online forms, live chat, social media, email, telephone, letters, face to face meetings;
- Sign up for alerts, mailing lists, newsletters or similar;
- Participate in a competition, survey, promotion;
- Visit our Website or use any of the Services;
- Respond to requests from us for the provision of Personal Data; and
- Submit forms or enquiries to us online
We may also obtain information about you, including Personal Data, from third party sources including but not limited to online or public databases, identity verification service providers and credit bureaus or reporting services. You expressly consent to our approaching third parties in connection with the purposes set out in the Privacy Policy.
3. Use of Personal Data
We generally use your Personal Data in connection with the following purposes:
- Processing registrations and carrying out KYC, CFT and AML checks;
- Verifying information provided and your eligibility to use the Services;
- Maintaining your Account;
- Operating, providing and administering the Services;
- Reviewing, monitoring, maintaining, developing, upgrading, improving and personalising the Services;
- Ensuring the security and integrity of the Services and their underlying infrastructure;
- Assessing and ensuring compliance with internal procedures and policies;
- Informing you of updates or amendments to our Terms and Conditions, policies, fees and other administrative information relevant to your use of the Services;
- Providing you with information relevant to your use of the Services which we consider may be of interest to you;
- Communicating with you and responding to complaints, queries and requests;
- Dealing with disputes and any related investigations or legal proceedings;
- Preventing, detecting and investigating fraud, money laundering and other crime;
- Providing assistance to and cooperating with law enforcement, judicial and governmental authorities;
- Protecting, performing and enforcing our legal rights and obligations;
- Complying with applicable law, regulatory requirements and guidelines;
- Conducting market research, data analytics and surveys to assist us in developing and improving our Services;
- Working with agents and third party service providers instructed in connection with the provision of the Services; and
- Facilitating any proposed acquisition, merger, partnership, joint venture, asset sale or purchase involving the Company or any of its affiliates.
The purposes set out above are non-exhaustive and you may be notified of additional purposes for which we use your Personal Data. We may also use your Personal Data in connection with the following marketing-related activities:
- Informing you of promotions, reward programmes, competitions, contests and events;
- Sending you newsletters and industry/market updates; and
- Targeted marketing in respect of third party goods and services which may of interest you
Should you wish to opt-out of such marketing activities please email us at [email protected] with the subject title “OPT-OUT Marketing” and once your email has been processed we shall no longer collect, process, use, share or disclose your Personal Data for such purposes. Should you wish to opt back in at any time thereafter please email us at [email protected] with the subject title “OPT-IN Marketing”.
4. Disclosure of Personal Data to Third Parties
We will take reasonable care to ensure that your Personal Data remains confidential and will only permit your Personal Data to be accessed by:
- Third parties who require access to it in connection with the provision of the Services or the performance of any obligations or activities described in this Privacy Policy or Terms and Conditions; or
- Third parties that have a legitimate basis for accessing it.
We will generally only share your Personal Data with the following parties in the following circumstances:
- In order to satisfy KYC/AML/CFT requirements, confirm your identity and to assist with the prevention of illegal activity such as money laundering and fraud, we may share your Personal Data with identity verification providers, credit bureaus or credit reporting agencies and transaction monitoring services;
- In order to facilitate the provision of the Services, we may share your Personal Data with service providers, vendors and agents that have been contracted to provide various services including but not limited to administrative, payment, payroll, financial, technological, marketing, operational, training, research, custodial and storage services;
- In order to obtain and maintain insurance, credit lines and banking facilitates we may share your Personal Data with insurance providers, credit providers and other financial institutions;
- In order to facilitate the promotion of products or services of third parties with whom we do business, we may share your Personal Data with those third parties;
- In order to facilitate a proposed merger, acquisition, assignment, asset sale or disposal, or similar business transaction, we may share your Personal Data with other entities or investors involved therewith;
- In order to comply with a court or tribunal order, subpoena or any other formal legal procedure or process, any investigation whether instituted by a third party or us, any applicable law or regulation, or where we in our sole discretion deem it necessary or prudent to do so, we may share your Personal Data with law enforcement agencies, regulators and government and inter-governmental agencies;
- In order to enforce our rights under the Terms and Conditions we may share your Personal Data with debt collection agencies and dispute resolution bodies;
- In order to seek professional advice, we may share your Personal Data with our professional advisors; and
- In other circumstances for which we have sought your consent pursuant to an amendment to the Privacy Policy or our Terms and Conditions, or email request.
Please note that the above is not an exhaustive list and we may share your Personal Data in other circumstance and to other third parties, in accordance with applicable law.
5. Internationals Transfers of Personal Data
We are headquartered in Singapore and so your Personal Data will be stored, primarily, in our data storage facilities in Singapore. In order to facilitate the provision of the Services we will also need to transmit your Personal Data to various third party service based in various jurisdictions around the world. This means that your Personal Data may be transferred to, processed and stored in multiple jurisdictions outside of your home jurisdiction or, if you are a resident or citizen of the European Economic Area, UK or any other jurisdiction to which the GDPR applies, in jurisdictions falling outside of any of the foregoing.
6. Security of Personal Data
The security of your Personal Data is of the utmost importance to us and we take all reasonable care to ensure that the Personal Data that we collect remains secure and protected from unauthorised access or use. Further to this we have adopted various technical and operational measures specifically designed to protect your Personal Data.
However, the security of your Personal Data cannot be absolutely guaranteed. No means of transmitting information via the internet or method of storing data can ever be viewed as completely secure. Therefore whilst we strive to adopt measures in line with industry standards in order to protect your Personal Data, we cannot guarantee its security.
7. Use of Cookies
Cookies are small pieces of data, stored in text files, that are stored on your computer, mobile phone or tablet when you visit a website, that allows that website or a third party to remember you and your preferences.
When you access our Website, we and other companies that we partner or work with, may store cookies on your web browser in order to help:
- Personalise your user experience;
- Monitor and improve the performance of the Website;
- Monitor how you arrive at the Website and what type of browser or operating system you are using;
- Monitor which pages you view, when you view them and for how long;
- Monitor the total number of visitors to the Website; and
- Facilitate advertising by us and third parties on the Website and third party websites.
By accessing or using the Services you consent to the storage of cookies on your electronic device as set out above. Notwithstanding all web-browsers provide the option of disabling cookies and so you may exercise this option if you choose. Please note that disabling of cookies may affect your user experience and you may not be able to access all parts of the Website or enjoy the full functionality of the Services offered.
7. Use of Cookies
Cookies are small pieces of data, stored in text files, that are stored on your computer, mobile phone or tablet when you visit a website, that allows that website or a third party to remember you and your preferences.
When you access our Website, we and other companies that we partner or work with, may store cookies on your web browser in order to help:
- Personalise your user experience;
- Monitor and improve the performance of the Website;
- Monitor how you arrive at the Website and what type of browser or operating system you are using;
- Monitor which pages you view, when you view them and for how long;
- Monitor the total number of visitors to the Website; and
- Facilitate advertising by us and third parties on the Website and third party websites.
By accessing or using the Services you consent to the storage of cookies on your electronic device as set out above. Notwithstanding all web-browsers provide the option of disabling cookies and so you may exercise this option if you choose. Please note that disabling of cookies may affect your user experience and you may not be able to access all parts of the Website or enjoy the full functionality of the Services offered.
8. Retention of Personal Data
Personal Data shall be retained for:
- as long as necessary to fulfil the purposes for which it was collected for;
- any retention period that is required by a compelling legal obligation (e.g. by law, pursuant to litigation or investigation which might arise, etc.);
- any retention period as per our Firm’s Retention Policy (details of which may be made available upon request).
In determining the appropriate retention period, our Firm gives careful consideration to applicable legal and regulatory requirements, the amount, nature and sensitivity of the data in question, potential risk of harm from unauthorised use or disclosure, and whether we could achieve the purposes at hand through other means.
9. Minor's Privacy
Our Services are designed to be used only by individuals who are at least 18 years old and when a User provides any information to us, that User represents that he or she is at least 18 years old. We do not knowingly collect any Personal Data from individuals under 18 years old and where we have reason to suspect that an individual submitting information to us is younger than 18 years old we shall require the immediate closure of the relevant Account. We will then take steps to delete or destroy any Personal Data collected in connection therewith. If you become aware of any individuals under the age of 18 using our Services please inform us immediately so that appropriate steps can be taken.
10. Third Party websites
Our website may contain links to third party websites. For the avoidance of any doubt any such third party websites are not covered by this Privacy Policy. If you wish to learn more about how a third party website collects and uses your Personal Data please consult that third party’s own privacy policy.
11. Your Rights
Depending on the Data Protection Laws applicable to you, you may be entitled to certain rights with respect to your Personal Data. We are only obliged to honour such rights to the extent that they have been conferred on you by applicable Data Protection Laws. We recommend you review your local Data Protection Laws in order to determine what right are available to you .
Such rights may include:
- Withdrawal of consent. You may be entitled to withdraw your consent in respect of any or all of the purposes set out in this Privacy Policy. Where you choose to withdraw such consent we may no longer be able to provide you with the Services and notwithstanding such withdrawal, where we are permitted or obliged to do so by applicable Data Protection Laws, we may continue to collect, use, process or share your Personal Data as appropriate.
- Access to Personal Data. You may be entitled to confirmation that we process your Personal Data and, if so, to request access to the Personal Data which we hold. We may, to the extent permitted by applicable law, charge a reasonable administrative fee for the provision of such information.
- Erasure. You may be entitled to request that we erase some of the Personal Data which we hold about you.
- Restriction. You may be entitled to require that we restrict or limit the further use of your Personal Data, so that such Personal Data is restricted to being used for certain purposes only.
- Objection. You may be entitled to object to the use of your Personal Data so that we are required to no longer use some or all of your Personal Data.
- Rectification. You may be entitled to request that we rectify any incorrect Personal Data or complete any incomplete Personal Data which we hold about you.
- Data Portability. You may be entitled to a copy of your Personal Data in a structured, commonly used, and machine-readable format, and you may have the right to transmit that Personal Data to another entity.
- Right of Complaint. If you consider we have breached your legal rights you may have the right to submit a complaint to the relevant regulatory or supervisory body. We recommend you first contact us at [email protected] so that we can attempt to address your concerns directly.
The above rights are not in any way guaranteed and even if the Data Protection Laws applicable to you or the relevant scenario provide for such rights we may not, due to an exception or other applicable law, be obliged to comply.
12. Updating Personal Data
In order to be able to provide you with the Services it is important that all Personal Data that you provide to us remains current and up to date. It is your responsibility to keep us updated of any changes to your Personal Data by emailing us at [email protected]. We shall not in any circumstances be held liable for any losses, costs, expenses, damages or liabilities arising from your failure to keep your Personal Data updated.
13. Governing Law
This Privacy Policy shall be governed by the laws of the Republic of Cyprus.
